3. Cross Connection Control Policy

BACKGROUND

The Kansas Department of Health and Environment (KDHE), Division of Environment, Bureau of Water, is responsible for enforcement of state laws concerning cross connection control. Kansas Statute Annotated (KSA) 65-163a provides that the water supplier may cease the delivery of water to any premises where a condition exists which might lead to the contamination of the public water supply. If the water supplier does not enforce this law, the Secretary of Health and Environment may order the supplier to cease delivery of water to said premises. KSA 65-171g prohibits the connection of sewage systems to the public water supply.

Kansas Administrative Regulation (KAR) 28-15-l8(h) requires that all community water systems and any high risk, as designated by the department, non-community system, shall have a regular program, approved by the department, for the detection and elimination of cross connections and prevention of backflow and backsiphonage.

PURPOSE

The intent of the policy document is to help establish local programs which protect public water supplies from contamination due to backflow. This policy document establishes guidelines for creation and management of local cross connection control programs.

POLICY

KDHE policy is to have public water supplies establish locally an appropriate cross connection control program conforming to guidelines presented herein. The local program shall provide for detection, prevention, and elimination of cross connections. Public water supplies are expected to be diligent in implementing and administrating cross connection control programs as they provide an important link in protecting the public drinking water from contamination.

KDHE will track development of and will approve local cross connection programs meeting the intent of this policy. KDHE will support educational efforts to inform water supply personnel of the hazards of cross connections.

KDHE will review and approve local programs meeting the following guidelines:

The “regular program” as noted in the regulation shall have the following basic elements:

1. A Kansas Department of Health and Environment approved ordinance, rule, bylaw or regulation.

(a) Acceptable model ordinances include the model prepared by League of Kansas Municipalities, KDHE, and Kansas Rural Water Association (KRWA).

(b) Ordinances following other models may be approved by KDHE.

2. An outline of how the ordinance will be enforced and who will be responsible for this enforcement.

(a) The outline must state the agency or agent responsible for carrying out the enforcement of the ordinance.

(b) The outline must state the procedure for assuring that all devices are properly installed, inspected, and tested.

3. A device inspection, testing and repair schedule.

(a) All backflow preventers must be inspected and tested regularly (at least annually).

(b) Repairs must be made as necessary to protect the integrity of the device.

4. A list of available trained device tester/repairmen.

The designated agency/agent needs to maintain a list of tester/repairmen in their immediate area. The list should be updated regularly. This list needs to include all persons who are qualified to perform testing, overhaul and repair of their devices.

5. A record of all backflow prevention devices, installation date, inspection date, inspector name, condition of the device, repairs, name of repair technician, and date of repairs must be maintained by the agency/agent responsible for the program. In addition to this record, a tag containing the above data is to be attached to each backflow preventer.

INFORMATIVE DATA

The following information is provided for more specific guidance in cross connection control:

DEGREE OF HAZARD

The water supplier needs to define degree of hazard and prescribe an appropriate backflow preventer. This approach is suggested since it is consistent with nationally accepted standards. The following should be considered a minimum definition:

“Degree of Hazard” shall be classified as either: (a) high (health hazard) or (b) low (non-health hazard). Health hazard is the potential threat of a physical or toxic nature to the public water supply that would be a danger to the health of the consumer of the water.

High hazards must be provided a physical separation (approved air gap), an approved reduced pressure principal backflow prevention device or must be protected by an approved pressure vacuum breaker.

EXPLANATION OF TERMS

High Health Hazard - Any substance that when introduced into the potable water may create a health hazard.

Low Non-Health Hazard - Any substance that may create a moderate hazard if introduced into the potable source.

Air Gap (AG) - A physical separation between the potable water and any contaminating source. Must be two pipe diameters but not less than one inch above the flood level rim.

Reduced Pressure Principal Device (RPPD) - A mechanical device used to prevent backflow due to back pressure and backsiphonage. Suitable for both toxic and non-toxic substances.

Pressure Vacuum Breaker (PVB) - A mechanical device used to prevent backflow due to backsiphonage. May be used under continuous line pressure.

Atmospheric Vacuum Breaker (AVB) - A mechanical device used to prevent backflow due to backsiphonage. May not be used under continuous line pressure.

Double Check Valve Assembly (DCVA) - A mechanical device used to prevent backflow due to back pressure and backsiphonage. Suitable for non-toxic substances only.

RECOMMENDED TYPES OF BACKFLOW PREVENTION DEVICES

HIGH DEGREE OF HAZARD SUBJECT TO BACK PRESSURE	TYPE OF DEVICE
1. Pumps, tanks and lines handling: a. Sewage and lethal substances b. Toxic substances	AG, RPPD AG, RPPD
2. Connections to steam or steam boilers: a. Boilers 400,000 btu/hr. or larger b. Boilers with chemical feeders	AG, RPPD AG, RPPD
3. Lawn sprinkler systems	AG, RPPD
4. Bulk chemical tanks	AG, RPPD
HIGH DEGREE OF HAZARD NOT SUBJECT TO BACK PRESSURE
1. Sewer connection waste lines	AG, RPPD, PVB, AVB
2. Low inlets to receptacles containing toxic materials (includes lawn sprinkler systems)	AG, RPPD, PVB, AVB
3. Coils or jackets used as heat exchanges in compressors, degreasers, or other equipment: a. In sewer lines b. In toxic materials	AG, RPPD AG, RPPD
4. Flush valve toilets	AVB
5. Toilet and urinal tanks	AG, AVB
6. Trough urinals	AVB (1)
7. Valved outlets with hose threads	AG, RPPD, PVB, AVB
8. Lawn sprinkler systems	AG, RPPD, PVB
9. Bulk Chemical Tanks	AG, RPPD
LOW DEGREE OF HAZARD SUBJECT TO BACK PRESSURE
1. Pumps, tanks and lines handling: a. Non-toxic materials	AG, RPPD, DCVA
2. Connections to steam or steam boilers: a. Boilers smaller than 400,000 btu/hr.	AG, RPPD, DCVA
LOW DEGREE OF HAZARD NOT SUBJECT TO BACK PRESSURE
1. Low inlets to receptacles containing non-toxic materials without chemical feeders	AG, RPPD, PVB, AVB, DCVA
2. Low inlets to domestic water tanks	Treat each case individually
3. Coils or jackets used as heat exchangers in compressors, degreasers, or other equipment: a. In non-toxic substances	AG, RPPD, DCVA

(1) AVB must be installed not less than 30 inches above flush tube.

NOTE:

1. Double Wall Heat Exchangers with atmospheric vent must always be used when heating potable water.

2. Low hazard boilers must have a properly air gapped blow-off.

DUAL CHECK VALVES

A common issue is the installation of backflow preventers, usually dual check valves, at each service connection. Installation of these devices at each service connection to the public water supply is not a requirement of KDHE. A backflow preventer needs only be installed where it is determined a cross connection exists, or the potential for a cross connection is imminent. Protection at every meter or any connection to the public water supply is an option of the water supplier.

Containment by installation of dual check valves may be used as an optional part of an overall local cross connection control program, but may not be considered the total answer to cross connection control. Isolation of contaminants at the point where they may enter the potable water is essential to the cross connection control program.

Installation of a dual check valve results in the consumers piping beyond the dual check valve becoming an enclosed system. The consumer may need to install a pressure relief device to allow for thermal expansion. The water supplier needs to inform the property owner of this potential problem.

Dual check valves need to be inspected, cleaned, and repaired at least every third year to protect the integrity of the device. This type of backflow preventer like any other device requires regular inspection and maintenance.

The dual check valve is approved for use only at the meter or service connection, and cannot be used in place of the double check valve assembly. The dual check valve cannot be tested whereas the double check valve assembly can. The dual check valve may be located in a meter box below ground while the double check valve assembly must be accessible for regular inspection, testing, and repair.

A single check valve is not an acceptable cross connection control device.

ISOLATION AND CONTAINMENT

Containment is a policy of protecting a water supply system by preventing cross connections in a building or premises from causing backflow into the distribution system. This is accomplished by requiring backflow prevention devices at the point of delivery of water to the customer. A containment policy does not serve to detect and eliminate cross connections and prevent backflow and backsiphonage as required by KAR 28-15-lB(h). An acceptable cross connection control program should stress finding and eliminating cross connections within the customer’s plumbing system.

GRANDFATHER CLAUSE

It is not appropriate to grandfather a premises where a cross connection or the potential for a cross connection may exist. It is appropriate to give highest priority to new construction. However, the program goal should be to detect and eliminate cross connections and prevent backflow and backsiphonage throughout the water supply system.